Mutual Agreement Procedure allows taxpayers to ask competent authorities to resolve treaty-inconsistent taxation through bilateral agreement.

Mutual Agreement Procedure permits a person alleging treaty-inconsistent taxation to present the case to the competent authority of the State of residence or nationality within the specified time limit. If the competent authority finds the objection justified and cannot itself resolve it, it must endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities must also consult to resolve interpretative doubts, eliminate double taxation beyond the Convention, communicate directly, and may use a Commission for oral exchanges.

---

---

---